https://www.taxtmi.com/caselaws?id=36129 The Tribunal allowed the assessee to raise a new ground of attack in appeal, even though it was not raised before the ITO. The court held that the penalty should be imposed for the entire default period from the original due date to the actual filing date, rejecting the Tribunal's view that penalty should only apply after the notice u/s 148. The court referred to relevant case law and ruled in favor of the assessee on the new ground issue but against them on the penalty imposition period. The assessee was directed to pay the costs of the reference to the Commissioner. en-us Mon, 04 Dec 1978 00:00:00 +0530 Fri, 19 Mar 2010 14:23:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36129 The Tribunal allowed the assessee to raise a new ground of attack in appeal, even though it was not raised before the ITO. The court held that the penalty should be imposed for the entire default period from the original due date to the actual filing date, rejecting the Tribunal's view that penalty should only apply after the notice u/s 148. The court referred to relevant case law and ruled in favor of the assessee on the new ground issue but against them on the penalty imposition period. The assessee was directed to pay the costs of the reference to the Commissioner. Case-Laws Income Tax Mon, 04 Dec 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36129